The OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length principle”, which is the international consensus on the valuation of cross-border transactions between associated enterprises. Let’s take closer look. Continue reading Transfer Pricing Requirements and other...
In addition, the study also will evaluate how Indonesias domestic rules can overcome the case if Starbucks UK case happens in Indonesia. There are three steps conducted in this study. First, using information provided by UK Her Majesty's Revenue and Customs (HMRC) and other related articles, ...
in principle, any value within the range satisfies the arm’s-length principle. If, on the other hand, it is possible to identify a point within the range that best matches the facts and circumstances of the controlled transaction in question, the adjustment should be made up to that point...
United States (1928).54 Nigro considered the constitutionality of Section 2 of the Harrison Narcotic Act which required that morphine be sold only pursuant to an order on an Internal Revenue form. The Court recalled having upheld Section 1's requirement that narcotics be sold only with a tax ...